Online Privacy Notice
Privacy Notice Effective Date: 1 August 2016
Scope of This Notice
This Privacy Notice (“Notice”) describes how Seabury Capital LLC (“Company,” “we,” “us,” and “our”) protects visitors (“you” and “your”) to a publicly accessible Seabury website (“Site”). This Notice applies only to personal information collected through such Sites. “Personal information” means information that identifies you personally, either alone or in combination with other information available to us. Your use of this site, contact with Seabury, and any dispute over privacy is subject to this Notice.
Specific Privacy Notices
This Notice may be supplemented or amended from time-to-time by specific privacy notices posted on our website. These notices will provide a level of detail that we cannot provide in this more general description of our privacy practices. For example, certain pages of this Site may contain specific privacy notices providing details about the personal information we collect on those pages, why we need that information, and choices you may have about the ways we use that information.
Our Commitment to Your Privacy
EU-US Privacy Shield
Seabury is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
US-Swiss Safe Harbor
Public Disclosure of Our Privacy Practices – the EU-US Privacy Shield ‘Notice’ Principle
On this Site, we also may provide hyperlinks to sites of our business partners and other relevant sites. If you visit these sites, please be sure to read their privacy policies. This Notice does not apply to those sites and we are not responsible for the content and experience you may encounter on those sites.
Limits on Information Collection and Retention – the EU-US Privacy Shield ‘Data Integrity and Purpose Limitation’ Principle
On this Site, we will collect and retain only the personal information that we need for business purposes or to comply with a legal obligation such as a subpoena or court order. When we ask you to provide your information in an online form, we’ll indicate which fields of information are required. If you do not provide this information, you may not be able to access certain areas of this Site or complete certain transactions.
What kind of information we collect:
We collect two types of information on this Site:
- IP addresses and “clickstream” information. In general, you can browse our Site anonymously. We may gather your computer’s IP address and “clickstream” information on the length of your stay, the pages you view, and your movement patterns through the Site. We collect this information to make the Site better and, in turn, make it a more enjoyable experience for you. We may also share this statistical information with our business partners.
- Information you provide. There are situations where you may voluntarily provide us your personal information. When you visit certain areas of this Site, we may ask for personal information from you, such as your name, mailing address, e-mail address, or software preferences. Providing this information is voluntary on your part.
How we collect information:
In addition to you completing forms on this Site, there may be other ways this Site collects information about your visit:
- Session cookies. A “session cookie” is a temporary cookie that expires when you close your browser. A session cookie assigns a randomly-generated, unique identification number to your computer when you access one of our Sites. Assigning your computer a number facilitates the proper functioning of the features of our sites, by permitting us to maintain a persistent “state” for your session. We also use session cookies to collect information about the ways visitors use our Site – which pages they visit, which links they use, and how long they stay on each page.
- Sessions cookies do not contain your personal information. If, however, you have created a user identity on one of your visits to our Site, we may link the session cookie identification number to information that identifies you personally.
- Persistent cookies. When you visit our Site, we may place one or more “persistent cookies” on your computer. Unlike a “session cookie,” a persistent cookie does not expire when you close your browser. It stays on your computer until it expires — for example, at the end of the calendar year — or until you delete it.Some persistent cookies simply “tag” your computer so that the next time you visit — or someone using your computer visits — our server will recognize you. It recognizes you, not by name, but by the “tag” on your computer. This will enable us to provide you with a personalized experience even if we do not know who you are. It will also allow us to collect more accurate information about the ways visitors use our Site — for example, how visitors use our Site on their first visit and how often they return. If, at some point, you create a user identity, we may link the information collected by these persistent cookies to information in our database that identifies you personally. We may also transfer this information to a cookie and place it on your computer’s hard drive so that our web server can read this information each time you visit our Site. In either case, using persistent cookies permits us to provide you with a more personalized experience and, in some cases, may save you the trouble of re-entering information already in our database.If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You may also delete our cookies as soon as you leave our Site. Although you are not required to accept our cookies, if you set your browser to reject cookies, you will not be able to use all of the features and functionality of this Web site.
- Web beacons. Web beacons — also referred to as “tracking pixels” or “action tags” — are graphic images that may be placed at various locations on our Site. Web beacons help us recognize the cookies on your browser. Like cookies, Web beacons help us collect information about the ways visitors use our Sites. They also help us identify browser types, IP addresses, search terms that bring visitors to our Sites, and the domain names of the websites that refer traffic to us. The information collected by web beacons does not identify you personally. However, if you have created a user identity on one of your visits to this Site, we may link the information we collect using web beacons to the information that identifies you personally and use it in the same ways as we use the information we collect using cookies. We also may utilize web beacons to provide us with more information on any e-mails we send out. In particular, the web beacons will send us information to let us know that you have received and opened any e-mail you have chosen to receive from us.
How we use your personal information with your consent:
We may use your personal information to process your inquiry, conduct customer surveys and marketing research, provide you with the latest product and promotional information, contact you regarding administrative notices, or perform other tasks related to Seabury’s products and services. We may also use the information you provide to send you brochures, allow you access to certain areas of the Site, establish e-mail contact with you, and process your requests.
Individual Consent for Marketing and Data Sharing – the EU-US Privacy Shield ‘Choice’ Principle
We will respect your preferences and choices for how we contact you regarding marketing and promotional communications. We provide you, for example, with opportunities to subscribe to e-mail lists. Your subscription to these lists is voluntary, and we will only use your registration information to provide you with related information in which you may be interested. We will not give or sell this e-mail list to anyone outside of Seabury, our subsidiaries, or our business partners for their own promotional purposes.
If you want to be removed from our mailing list, please click the “unsubscribe” link at the bottom of the e-mail you received from us. Even after you unsubscribe, you may continue for a time to receive communications from us that were already in progress. However, you will not receive a marketing e-mail from us more than 10 days after you’ve submitted your request.
We may share your information with Seabury’s service providers for the purpose of providing and servicing your Company products and supporting your ongoing relationship with Seabury. We understand that your information is important and we will not sell or give this information to any other company for its use in marketing or solicitation.
There are other circumstances in which we may share your personal information with third parties. For example, we may disclose your personal information to a third party when we, in good faith, believe disclosure is appropriate to comply with the law or a regulatory requirement or to comply with a subpoena or court order, including to meet national security or law enforcement requirements; to prevent or investigate a possible crime, such as identity theft; to enforce a contract; to protect the rights, property, or safety of Seabury or a third party; or to protect your vital interests. We are committed to cooperating with EU data protection authorities, and will comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of an employment relationship.
In addition, your personal information may be transferred to another company that has acquired the stock, or all or part of the assets of Seabury – for example, as the result of a sale, merger, reorganization, dissolution, or liquidation. If such a transfer occurs, the acquiring company’s use of your personal information will still be subject to this Privacy Notice and the privacy preferences and choices you have expressed to us. Therefore, although we are committed to maintaining the privacy and security of your personal information to the extent possible, we cannot and do not promise that your personal information will always remain private.
Secure External Data Transfer – the EU-US Privacy Shield ‘Accountability for Onward Transfer’ Principle
We will hold our service providers accountable when they perform services on our behalf that involve accessing your personal information. We authorize our service providers to use your personal information only to perform services on our behalf. We may change service providers from time to time with or without notice to you, but will require any new service providers to protect your personal information in strict accord with the standards we have described in this Notice.
You should know that different countries have different data-protection laws, some of which provide more protection than others. When you submit personal information to Seabury you understand and agree that such information will be transmitted across national boundaries stored in Seabury facilities in the United States and the Netherlands. In all such cases, we take appropriate measures to protect your personal information. Please rest assured, no matter where we transfer your personal information, it will remain subject to the terms of this Notice and your privacy preferences. We share the personal information we collect with third-party service providers and others around the world as described in this Notice.
In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Seabury is potentially liable.
Information Security – the EU-US Privacy Shield ‘Security’ Principle
We want you to have continuing trust in Seabury and in our products and services. To that end, we’ve put in place reasonable physical, technical, and organizational procedures to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Unfortunately, no security measures can be guaranteed to be 100-percent effective. It is important that you understand that no website or database is completely secure or “hacker proof.” It is also important for you to guard against unauthorized access to your passwords and the unauthorized use of your computer.
Information Access and Accuracy – the EU-US Privacy Shield ‘Access’ Principle
You may review and correct your personal information that we hold by requesting this information by contacting us at:
Attn: Privacy Officer
222 South 9th Street, Suite 3250
Minneapolis, MN 55402 USA
If you write to us, please provide your name, mailing address, and a clear description of the information you wish to review or correct. We will respond promptly within the time limits established by applicable law, but at least within 30 days of your request. For your protection, we may ask you for additional information to verify your identity. In most cases, we will provide the access you request and correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if the law permits or requires us to do so. We encourage you to promptly update your personal information you hold with us if it changes.
Policy Compliance and Accountability – the EU-US Privacy Shield ‘Recourse, Enforcement and Liability’ Principle
We communicate our privacy principles to all of our employees and train those employees handling personal information on their roles and responsibilities in protecting your privacy. We also regularly assess the privacy and security practices of our Site, databases, and other information systems to identify ways we can improve our data practices.
If you have any concerns about the privacy or security of your personal information, please contact us at firstname.lastname@example.org. We will attempt to resolve your inquiry in a timely manner.
Attn: Privacy Officer
222 South 9th Street, Suite 3250
Minneapolis, MN 55402
We have further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.\
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
Attn: Privacy Officer
222 South 9th Street, Suite 3250
Minneapolis, MN 55402
We have further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
Our Site is not directed at nor targeted to children. No one who has not reached the age of majority in his or her country may use this Site unless supervised by an adult.
We do not use our Site to knowingly solicit personal information from or market to anyone under the age of majority in his or her country. Our goal is to comply with applicable laws and regulations relating to collection and use of information from children, including the Children’s On-line Privacy Protection Act of the United States. If you believe that we have received information from a child or other person protected under such laws, please notify us immediately by postal mail addressed to Seabury Capital, ATTN: Privacy Officer 222 South 9th Street, Suite 3250, Minneapolis, MN 55402 USA or via e-mail at email@example.com. We will take reasonable steps to remove that information from our databases.
Unless applicable law prohibits it, this Privacy Notice and any specific Privacy Notices are governed by the laws of the State of Minnesota, United States of America, without regard to its conflict of law principles.
Country-Specific Privacy Notices
All EU Countries and Switzerland
Where Will Your Personal Information Be Processed?
Seabury is a global corporation comprised of Seabury Capital and its subsidiaries. Seabury Capital is a U.S. Corporation with offices at 222 South 9th Street, Suite 3250 Minneapolis, MN 55402 USA. Company Sites are hosted on servers located within the United States, and the Netherlands. Your personal information may be stored on these servers. In addition, Seabury may transfer your personal information to its partners, service providers, product manufacturers, licensers, suppliers, and others located in the United States or another country located outside the European Union (“EU”) or Switzerland as described in this Policy.
You should note that, at present, the laws of the United States and many other countries outside the EU and Switzerland have not been approved by the European Commission as providing “adequate protection” for personal information within the meaning of the EU Data Protection Directive (95/46/EC). Please know, however, that no matter where your personal information is collected, used, transferred or stored, if it was collected through one of our Sites, it will be protected by the terms of this Notice, any specific Privacy Notices that apply to you, and by the Privacy Shield principles.
We reserve the right to update or modify this Notice, at any time and without prior notice, by posting the revised version of this Notice on this Site.
To alert you to these changes, we will update the effective date of this Policy. We will also provide a notice at the top of this Policy for at least 30 days after the new effective date and highlight the changes so that you can locate them easily. Unless the change is a minor change — such as a change in our contact information — or a non-substantive change, such as the reformatting of our Policy, we will post notices on the page where you submit your information or on other relevant pages of this Site for 30 days after the new effective date. Your continued use of this Site following any such change constitutes your agreement that all personal information collected from or about you through this Site after the revised Notice is posted will be subject to the terms of the revised Notice.